As the Trump administration continues to undermine labor protections that keep our children and patients safe, we urge you to join us in submitting the letter below as a public comment for the Notice of Proposed Rulemaking (NPRM) published on September 27,
2018. This NPRM would modify one of the Department of Labor’s Hazardous Occupations Orders (HO7) and remove the operation of power-driven patient lifts from the list of prohibited activities for 16 and 17-year olds.

Currently, HO7 has a non-enforcement policy that allows 16 and 17-year old children to assist with the use of power-driven patient lifts as long as they have received training and are operating the lift with an adult. But the administration claims that this
non-enforcement policy is not enough and that the whole prohibition should be scrapped.

As the letter states, this action is very concerning for several reasons, including the danger it poses for the health and wellbeing of minors operating these patient lifts on their own and without proper training. The move is contrary to recommendations
made by experts at the National Institute for Occupational Safety and Health (NIOSH) regarding the use of power-driven patient lifts by minors in the healthcare industry.

The proposed carve-out would also put patients at risk of accidents resulting from the improper use of patient lifts and from minors lacking the body strength to properly help patients on and off the lifts. For older patients, these risks are aggravated
and could result in severe injuries or death.

The administration claims it is making this change under the guise of expanding apprenticeship opportunities, but it uses questionable data to justify the change. In particular, it cites an unscientific 2012 survey from the Massachusetts Department of Public
Health to vocational schools in which there were only 22 respondents, half of which responded that they were not aware of the existence of the non-enforcement policy currently in place.

We believe it is critical to the wellbeing of our vulnerable children and patients that the Department of Labor use sound scientific evidence and expert recommendations from NIOSH in making any changes to the Hazardous Occupations Orders. Please join us
in expressing our opposition to changes that cater to industry at the expense of the health, safety, and wellbeing of children and patients. To sign on to the letter please contactJose.Miranda6@mail.house.gov (Roybal-Allard),Elizabeth.Albertine@mail.house.gov (DeLauro), orYuri.Beckelman@mail.house.gov (Takano)by COB Friday, December 7, 2018.